Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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For benchmarking research support services, a company selected as a comparable was held to fail the turnover filter since its turnover was only INR 3.65 crores; the AO/TPO was directed to rework the arm's length analysis by applying filters correctly and excluding that company, with consequent TP adjustment, if any, to be recomputed. On disallowance of employees' PF contribution for delayed credit, where the assessee had remitted the amount and it was debited from its bank within the stipulated date but credit to EPFO was delayed due to technical glitches beyond its control, the disallowance was deleted and the ratio in Checkmate Services was held inapplicable, resulting in the appeal being allowed. - ITAT
For benchmarking research support services, a company selected as a comparable was held to fail the turnover filter since its turnover was only INR 3.65 crores; the AO/TPO was directed to rework the arm's length analysis by applying filters correctly and excluding that company, with consequent TP adjustment, if any, to be recomputed. On disallowance of employees' PF contribution for delayed credit, where the assessee had remitted the amount and it was debited from its bank within the stipulated date but credit to EPFO was delayed due to technical glitches beyond its control, the disallowance was deleted and the ratio in Checkmate Services was held inapplicable, resulting in the appeal being allowed. - ITAT
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